To ensure consistent Bank Secrecy Act (BSA) coverage across the banking industry, the Financial Crimes Enforcement Network (FinCEN) is proposing to require banks lacking a Federal functional regulator to establish and implement Anti-Money Laundering Programs. FinCEN also is proposing to extend Customer Identification Programs (CIP) requirements and beneficial ownership requirements consistent with the recently implemented Customer Due Diligence amendments to those banks not already subject to these requirements.

Banks without a Federal functional regulator (FinCEN estimates that they number 740 nationwide) are currently covered by many other BSA obligations, including filing suspicious activity reports and currency transaction reports. FinCEN anticipates that banks lacking a Federal functional regulator will be able to leverage existing policies, procedures, and internal controls required by other statutory and regulatory requirements to fulfill the proposed obligations.

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